On March 22, 2020, Steve Mnuchin, Secretary of the Treasury, released a memorandum providing that the financial services sector is identified as Critical Infrastructure Sector by the Department of Homeland Security. This means that despite the restrictions put in place to slow the spread of COVID-19, essential workers in the financial services sector must maintain their operations and work schedules.

According to the memorandum, essential workers in the financial services sector include workers who are needed to:

  • Process and maintain systems for processing financial transactions and services, such as payment, clearing and settlement services, wholesale funding, insurance services, and capital markets activities
  • Provide consumer access to banking and lending services, including ATMs, movement of currency (e.g. armored cash carriers)
  • Support financial operations, such as those staffing data and security operations centers; and, key third party providers who deliver core services.”

In order to demonstrate that they must go to work, the American Banking Association has advised all bank employees designated as essential workers (as defined above) to carry copies of the memorandum as well as the guidance from the Department of Homeland Security’s Cybersecurity and Infrastructure Security Agency designating financial services as a critical infrastructure sector.